The United States
expresses its thanks to the Governments of Australia and the Philippines
for hosting the 17th Session of the Codex Committee on Food Import
and Export Inspection and Certification Systems (CCFICS).
The 17th Session was productive with outcomes that should be helpful
to both the United States and its stakeholders.
- Completed work on a Generic Model Official Certificate as an
Annex to the Codex Guidelines for the Design, Production,
Issuance and Use of Generic Official Certificates (CAC/GL
- Progressed work on the development of Proposed Draft Principles
for the Conduct of Foreign On-Site Audits and Inspections.
- Agreed to undertake new work to develop Principles and Guidelines
for National Food Control Systems.
The Committee did not, however, approve new work to develop implementing
guidance relating to traceability/product tracing. Additionally,
it did not approve new work to undertake the development of guidance
relating to the intentional contamination of food, indicating that
such guidance, with respect to intentional contamination arising
from economic adulteration already existed or, with respect to intentional
contamination resulting from directed and purposeful addition of
a hazard, generally fell outside the mandate of Codex and/or the
Terms of Reference for CCFICS.
The 17th Session of CCFICS was attended by 165 participants representing
69 Member countries, one Member organization (the European Community
(EC)), and seven international intergovernmental and non-governmental
organizations. The United States was represented by: the Delegate,
Ms. Mary Stanley, USDA Food Safety and Inspection Service; the Alternate
Delegate, Dr. Michael Wehr, FDA Center for Food Safety and Applied
Nutrition; and three government advisors and one non-government
A complete summary of the results of the 17th Session of CCFICS
is given below. The full report of the Session can be found in ALINORM
09/32/30 on the Codex Web site, www.codexalimentarius.net.
Proposed Draft Generic Model Certificate as an Annex to
the Codex Guidelines for Design, Production, Issuance and Use
of Generic Official Certificates (CAC/GL 38-2001, rev. 2008)
At the 16th (2007) Session of CCFICS, the Committee, based on a
proposal from the European Community, agreed to undertake work on
a model generic official certificate for use in food exporting.
The work was to be an Annex to the existing Codex Guidelines
for Design, Production, Issuance and Use of Generic Official Certificates
(CAC/GL 38-2001, rev. 2008). A physical Working Group was held between
sessions to develop a draft document for the Committee's consideration
(the United States was part of the Working Group).
The Committee held an extensive discussion of the proposed certificate
including both the accompanying explanatory narrative and the model
template certificate. The key outcomes of this discussion included
- Removing "sanitary" from the title, broadening the use of the
certificate to encompass the dual mandate of Codex (protecting
the health of consumers and facilitating fair practices in the
- Streamlining the narrative, removing language on provisions
already covered in the main Guideline document.
- Noting that the certificate could cover multiple product types
in a single certificate.
- Adding a general statement noting that if the consignee, port
of entry, or transport details change after the certificate has
been issued, it is the responsibility of the importer to advise
the competent authority of the importing country and that such
a change should not result in a request for a replacement certificate
to be issued.
- Noting the optional nature of several of the certificate elements,
including this aspect in the accompanying narratives for the elements
with wording such as "where available", "if required" and "where
- Including a new paragraph relating to the type of certificate,
that is, "original", "copy" and "replacement".
- Deleting any reference regarding "in transit" including information
relating to contact individuals, noting that certifying authorities
in exporting countries would not have knowledge of this information.
- Changing "expected border post" to "port of entry" and making
this an optional element noting that competent authorities of
the exporting country may not have knowledge of this information.
- Regarding country of origin, deleting the word "finished" before
"products" to broaden the applicability of the certificate.
- Making the requirement for indicating the means of transport
more flexible, providing for a generic description (e.g., air,
ship, rail) and making more detailed information such as flight
numbers, rail car numbers optional.
- Creating flexibility with respect to seal/container numbers
by making this information optional.
- Discussing the use of HS (harmonized system) codes with respect
to commodity identification, noting that HS codex are often not
sufficiently precise and are difficult to use, and deciding to
qualify the use of these codes "as appropriate".
- Revising the spacial layout of the certificate to make it as
consistent as possible with the OIE generic export certificate.
The Committee completed work on the certificate and agreed to recommend
its adoption by the Codex Alimentarius Commission at Steps 5/8 of
the accelerated procedure.
Proposed Draft Principles and Guidelines for the Conduct
of Foreign On-Site Audits and Inspections
At its 2007 (16th) Session, the Committee agreed to undertake work
on the development of guidance for the conduct of foreign on-site
audits and inspections, with work to be led by Australia. A physical
Working Group was held between sessions to develop the text considered
by the Committee (the United States was part of the Working Group).
Because of limited time, the Committee's discussion focused primarily
on the scope of the document and on an initial consideration of
the Principles presented in the draft text. No discussion occurred
on the detailed guidance.
The Committee agreed that the document would replace the existing
annex on audits contained in the Codex Guidelines for the Design,
Operation, Assessment and Accreditation of Food Import and Export
Inspection and Certification Systems (CAC/GL 26-1997), expanding
on Section 9 of this document.
A lengthy discussion was held on the scope of the document. Many
delegates indicated that the document should be limited solely to
system audits and inspections with inspections only noted as one
component of a system audit. Other countries, including the United
States, noted that some competent authorities carry out separately
both system audits and inspections to assess and verify the competency
of an exporting country's food control system or component parts
thereof. The committee developed a compromise text to resolve the
different views, as follows.
"In the context of a relationship between two countries, an importing
country may use tools for examination (i.e., audits and inspections),
to assess an exporting country's official inspection and certification
systems. These activities should concentrate primarily on the
effectiveness of the official systems. This annex is not intended
to mandate these activities but to provide guidance in the case
that they are used.
"While there are a number of tools available for the assessment
of an exporting country's official inspection and certification
systems, this annex is focused on the use of audits and inspections
for this purpose. The preferable tool is the use of audits. However,
in some instances, inspections may be used and guidance is provided
for these instances."
The Committee also clarified in the objective statement that the
"annex applies equally to assessments carried out on-site or by
The Principles were reviewed, noting among others, the following
- Principle (a) was adjusted to include the notion that audits
were linked to products or groups of products.
- Principle (b) was amended to indicate that audits should be
functionally independent, evidence-based and conducted in a cooperative,
ethical and professional manner including respecting confidentiality,
- Principle (c) was amended to avoid the term "dispute resolution"
to not confuse the resolving of concerns associated with an audit
with the WTO dispute resolution process.
Additionally, under Principle (i) it was agreed to discuss the
area of audit publication, specifically a proposal that the audit
report may be published when agreed to by the parties.
The Committee returned the document to Step 2 for further redrafting
and established a physical Working Group for this purpose. The Working
Group will be chaired by Australia and hosted by the United States.
Discussion Paper on the Need to Develop Principles and
Guidelines for National Food Control Systems
The Committee considered a revised Discussion Paper prepared by
Australia proposing that CCFICS undertake new work to develop Principles
and Guidelines for National Food Control Systems.
The Committee expressed general support for undertaking the work
and that CCFICS was the appropriate Codex committee to do the work.
Several countries noted the importance of this type of guidance
to countries whose food control systems were still in the early
stages of development noting that such guidance would assist both
with foods produced for domestic consumption and foods destined
The Committee revised and approved a Project Document for the work
with a recommendation to the Codex Alimentarius Commission to approve
the new work. The Committee also established a physical Working
Group to develop an initial text with the Working Group to be chaired
by Australia and hosted by the United States.
Discussion Paper on the Development of Guidelines for Traceability/Product
Tracing In the Context of Food Import and Export Inspection and
At the 2006 Session of CCFICS, following completion by
CCFICIS on Principles for Traceability/Product Tracing as a
Tool within a Food Inspection and Certification System, Norway
suggested that new work be undertaken on developing implementing
guidance for traceability/product tracing (T/PT). The Committee
agreed to have Norway prepare a Discussion Paper on the subject.
The Paper was considered at the 2007 Session of CCFICS and Norway
was asked to revise the Paper to provide more specific information
on the rationale for, and scope of, the guidance. Norway developed
and circulated a questionnaire, requesting information from countries
on the nature of T/PT information maintained by countries, to identify
gaps in existing implementing guidance and to seek information on
the specific work Codex might undertake in this area. The results
of the questionnaire formed the basis for a revised Discussion Paper
presented at this Session of CCFICS.
The Discussion Paper noted that the results of the questionnaire
did not clearly identify gaps and a specific need for implementing
guidance for T/PT. Additionally, the Paper noted that many countries
that had, as yet, not implemented T/PT systems did not respond with
information as to what specific Codex guidance was helpful or needed.
The Discussion Paper therefore proposed that work on the topic
be suspended until further discussion on the need for T/PT guidance
could be held at the FAO/WHO Regional Coordinating Committees and
that countries could identify appropriate work for CCFICS on this
subject. The Committee endorsed this approach and the issue was
removed from the CCFICS Agenda. No further discussion is expected
on T/PT until at least 2011 following discussion at the next sessions
of the various FAO/WHO Regional Coordinating Committees.
Discussion Paper on the Development of Guidance on the
Prevention of Intentional Contamination of Food
The United States, at the 2007 Session of CCFICS, noted that it
may be useful for CCFICS to undertake new work on the prevention
of intentional contamination of food. The U.S. noted that the potential
for harm to human health and trade arising from intentional contamination
of food was significant and that guidance for intentional contamination
of food differed from existing guidance on the unintentional contamination
of food. The Committee agreed to have the United States prepare
a Discussion Paper on the subject but indicated that the Paper should
clearly indicate the nature of the work, the gaps existing in current
Codex guidance including a review of existing CCFICS texts, and
whether the work fell within mandate of Codex and within the Terms
of Reference of CCFICS.
The United States prepared a Discussion Paper addressing the Committee's
requests and noting that the scope of the work would include both
intentional contamination arising from economic adulteration in
which harm is caused and intentional contamination arising from
the direct and purposeful addition of a hazard to a food.
The Committee acknowledged that intentional contamination of food
was an important issued but questioned whether CCFICS guidance was
needed. Several delegations noted that guidance relating to the
control of intentional contamination arising from economic adulteration
already generally existed. Further, some delegations noted that
they believe that purposeful intentional contamination of food was
outside the mandate of Codex as it was the result of criminal behavior.
The Committee agreed that it would not recommend new work in this
area but noted that some aspects of the control of intentional contamination
could be considered in the context of work to be undertaken on guidance
for national food control programs.
As part of a general review of Codex work management processes including
the criteria for undertaking new work, the Codex Alimentarius Commission
requested several committees to assess whether specific criteria,
in addition to those given in the Codex Procedural Manual,
were needed. CCFICS, prior to the specific review of this area by
the CAC, had briefly considered this subject noting that criteria
specified in the Procedural Manual were adequate for its'
purposes. Further, that no additional criteria relating to priority
setting were needed as CCFICS generally had only a few work items
on its agenda at any one time.
The Committee reconsidered this area based on the CAC's request.
As before, the Committee indicated that the criteria for new work
specified in the Procedural Manual were sufficient including
the general criterion and the criteria applicable to general subject
committees, and further, that no additional criteria relating to
setting work priorities were needed.
Next Session of CCFICS
The 18th session of CCFICS is tentatively scheduled for Nov 9-13,
2009 at a location to be determined.